LPHCA Response to Greater Manchester Air Quality Consultation

Steph FarrerNews, News 2019

As part of our rapid national expansion, the LPHCA is responding to important consultations on behalf of our growing national private hire operator membership. We have published here the Greater Manchester Air Quality Consultation, alongside our response.

Greater Manchester Air Quality Consultation

Greater Manchester is on a Journey to Cleaner Air
We’re already making progress, but we need to quickly do more to improve air quality now and for future generations. In Greater Manchester, poor air quality contributes to the equivalent of 1,200 deaths a year. Air pollution can contribute to a wide range of illnesses and conditions, including lung and heart diseases, some cancers, strokes and asthma.

A key element of the air pollution issue is nitrogen dioxide which is at levels above legal limits at numerous sites within Greater Manchester. In towns and cities,the main source of nitrogen dioxide is road vehicles, in particular older, diesel vehicles.

The Greater Manchester Clean Air Proposals
The full details of the proposals can be found in the summary of our proposals to improve air quality for Greater Manchester, available on their website. The proposals include:

  • a Clean Air Zone for buses, coaches, taxis, private hire vehicles and HGVs across Greater Manchester implemented in 2021, extending to vans, minibuses, motor homes and motorised horseboxes in 2023. It would not include cars (other than private hire vehicles), motorbikes or mopeds.
  • the Clean Air Zone would cover the whole of Greater Manchester, so we don’t shift pollution from one area to another. In our current proposal, the boundary of the Zone is, in broad terms, the administrative boundary of Greater Manchester.

As well as the above points, there are some additional proposals:

  • a number of Government-funded schemes for people and businesses in Greater Manchester who own vehicles that would be subject to the Clean Air Zone daily penalty; this financial support would help them to upgrade to compliant vehicles
  • installing another 600 rapid charging points (300 double-headed chargers) across the ten council areas of Greater Manchester
  • helping people, businesses, and organisations, including schools, across Greater Manchester play their part to reduce air pollution

Which Vehicles are Affected by the Proposed Clean Air Zone?
You can check whether you would be likely to pay a daily penalty to enter or travel within the proposed Clean Air Zone at vehicle checker. The emissions standards have been specified by Government. Vehicles with Euro 6 diesel engines, Euro 4 or newer petrol engines and ultra-low emission vehicles are compliant, so would not pay a daily penalty in the Clean Air Zone.

Next Steps
The GM Clean Air Plan proposals will be developed in more detail over the coming months. This is your opportunity to share your views and help us develop the right solutions for Greater Manchester.

In the future, there will be a statutory public consultation which will give you an opportunity to have your say on the detailed Clean Air proposals.

In Greater Manchester, poor air quality contributes to the equivalent of 1,200 deaths a year. It is the largest environmental risk to public health in the UK. Air pollution can contribute to a wide range of illnesses and conditions, including lung and heart diseases,some cancers, strokes and asthma.

  • To what extent do you agree or disagree that the air quality needs to be improved in Greater Manchester
    • We agree
  • Do you have any comments on the process and selection of the GM Clean Air Plan proposals?
    • To achieve the objectives of the plan from the perspective of the taxi and private hire vehicle (PHV) industry, requirements, timelines and the circumstances of both operators and drivers need to be extremely well considered alongside the needs of users. Taxis and PHVs are an un-subsidised mode of door-to-door transport that many vulnerable, elderly, special needs and disabled passengers are completely dependent upon. As well as this, taxi and PHV use dramatically reduces car ownership and provides options where buses, trains, trams, etc., do not pass through or cannot easily be accessed eg. in narrow roads or other less accessible places, near to tower blocks, etc.
    • We believe the decision to introduce a Clean Air Zone across the whole of Greater Manchester where owners of the most polluting vehicles would pay a daily penalty to enter and/or travel within the Clean Air Zone is sound. We are, however, nonplussed that cars (other than private hire vehicles) are not included and feel this is discriminatory against a trade that reduces car ownership and provides transport at low cost for the lowest socio-economic groups, the vulnerable and the disabled.
    • It is a fact that hospitals, railways, local authorities, and businesses, as well as the travelling public, now heavily utilise taxis and PHVs. They are absolutely dependent on getting their staff back and forth to work, usually when other modes are not running or disrupted.
    • These groups are now having low-emission charges passed onto them where they have been introduced, which makes not including private motorists a bizarre proposition as they are likely to travel more in their own vehicles, which may be older and far more polluting.
    • A primary reason for taxi and PHV usage nowadays is the fact that many taxis and PHVs are a very affordable and safe option. The fact that taxis and, particularly, PHVs are available 24 hours a day, every day of the year, is also a major consideration. Other key reasons for usage are convenience,cost and safety. Technology has enabled simplicity of booking and massively reduced empty vehicle mileage, it has also increased passenger carrying per mile driven.
    • With many modes of alternative transport being unreliable,expensive and in some cases very unsafe, there has been considerable mode switch in recent times away from heavily subsidised and often underutilised modes, in particular buses, which are often afforded a great deal of road space, sometimes disproportionate from the number of passengers being carried.
    • The media has, in the past few weeks, highlighted stories of a male passenger being knifed to death on a train in front of his 14-year-old son, frail people being pushed onto live electric tube-line tracks and a LGBT couple being subjected to a violent homophobic attack on a bus, all caught on CCTV, which made no difference whatsoever to the attackers. With taxis and PHVs being a 'far safer viable alternative' the public have made significant modal switch to these safer licensed and un-subsidised door to door modes.
    • It should also be mentioned in the context of the GM Clean Air Plan proposals that private hire has 'year-on-year' become cleaner and greener and for this reason it has become a primary transportation choice for many users alongside, cost, convenience and safety considerations.
    • The LPHCA welcomes and applauds Greater Manchester's efforts to improve air quality but cautions against there being a 'silver bullet' to the authority's aspirations for Greater Manchester, particularly for taxis and PHVs.
    • The LPHCA has worked closely with the Department for Environment Food & Rural Affairs (DEFRA) and the Department for Transport’s Joint Air Quality Unit (JAQU) as a primary stakeholder. Our Chairman Steve Wright MBE was also personally tasked by former London Mayor Boris Johnson to broker talks and dialogue between the industry,its vehicle manufacturers and Transport for London on the Air Quality requirements in London, especially with regard to the Ultra-Low Emission Zones (ULEZ).
    • Mr Wright subsequently set up the meetings as requested and organised talks on strategy and implementation for improved Air Quality in the capital with regard to taxis and PHVs. In spite of all the hard work there were delivery problems with timelines and implementation.
    • Original plans were modified and improved via further dialogue with all parties on all aspects. Unforeseeable problems (in particular, the failure to deliver anywhere near enough charging infrastructure for electric vehicles, the loss of grant money, lack of supply of appropriate electric vehicles and extreme costs) have all inhibited progress.
    • With the benefit of experience/hindsight we are able to share these with metropolitan authorities like Manchester, hence the preceding context that we have supplied with our submission.
    • Many PHV (and taxi) drivers are self-employed, and those who buy a car often do so over a well-planned repayment period via finance. Some are locked into five-year hire/lease purchase agreements, for example, with penalties for early termination. By introducing air-quality charges whilst they are in a repayment period, they lose money as these charges are not easily recoverable for air quality on a job-by-job basis.
    • A compliant vehicle on say a £3.50 job would charge £3.50, a non-compliant driver would have £7.50 to add to a fare, making the fare £11.00. This in itself is a nightmare to manage. As the PHV and Taxi workforce is predominantly self-employed and the owner (registered keeper) of the vehicle could be the driver, the operator, a hire car company, a relative or even an accident repair/maintenance replacement vehicle, collecting air quality charges is very complex.
    • By having a 2021 implementation date, in fairness to Greater Manchester, drivers have a reasonable opportunity time-wise but some will be trapped with vehicles that they planned to use beyond 2020. Worse still as their vehicles won't be air quality compliant, they won't get much for the vehicle, as the residual value will have fallen through the floor.
    • We are not suggesting that the air quality program should be shelved, far from it. What we are pointing out is the catch 22 situation such drivers will be in, and they are already under considerable pressure from the so called 'off-shore regulatory disruptors' who make their tax arrangements outside of the UK and artificially bring down prices with venture capital money subsidy.
    • With all the Greater Manchester local authorities applying for grant funding for environmental improvements and it being awarded ad-hoc at different levels and then passed on via differing criteria, many taxi and PHV drivers will get caught in a situation where they can't get help and could end up in a poverty trap.
    • In our view, quite wrongly (on the basis of equality and discrimination) hackney carriages (taxis) have, in some areas, been exempt and awarded scrappage incentives, sometimes by virtue of the fact that they are wheelchair accessible; however PHVs are often the preferred choice of the non-wheelchair bound disabled and special needs passengers, as well as the elderly If there are to be exemptions they should be for both taxi and PHV,  otherwise this, in our view, is discrimination and fails equality requirements.
    • It is therefore critical that you look at the difficulties faced by all taxi and PHV drivers in this regard and that funding is found across Greater Manchester to help with upgrading by incentives and scrappage schemes.
    • We note you state: Any income from the Clean Air Zone would be used to cover its running costs. After that,any leftover money would be spent on improving transport in Greater Manchester.This might include improvements to public transport, including park and rides,and cycling and walking schemes.
    • The LPHCA contends that taxi and PHV is an essential form of public transport: the '24 x 7, 365-days door-to-door' mode. There are nearly half a million people working in or directly employed as a consequence of the sector in the UK with around 1/3 million being drivers. It is an un-subsidised transport mode that, in our view, should not be subsidising other modes, many of which are already heavily subsidised and not contributing to the exchequer.
    • Any excess revenue from taxis and PHVs should be ploughed back into scrappage or infrastructure schemes that aid and abet improvements to the air-quality footprint for this vital 'door-to-door' element of transport provision.
    • As part of the government's recent Task and Finish Group on Taxi and Private Hire Vehicle licensing chaired by Professor Mohammed Abdel-Haq, the LPHCA is pleased to see Greater Manchester is currently looking for common standards across the traditional local authorities. We look forward to working with the trade and Greater Manchester regarding the Proposals for Taxi and Private Hire Minimum Licensing Standards published this month.
    • The LPHCA was instrumental is getting the Private Hire Vehicles (London) Act 1998 onto the statute, and it is timely that the air quality proposals are in the same window of opportunity for all concerned in the trade alongside the regulators.
    • It is very important that where possible the authorities in the Greater Manchester area co-ordinate incentives, scrappage schemes and infrastructure provision for both the taxi and PHV trades so there is consistency in levels of help and delivery across all the authorities.
    • The LPHCA is now a trade body with a national footprint and following our successful and inaugural forum in Manchester this April, which filled the main conference facilities at the Emirates Old Trafford in April, we look forward to working with Greater Manchester, the Local Authorities therein and both the taxi and PHV trade in the North West, in particular with regard to air quality requirements and common standards of safety and regulation.

The Proposed Clean Air Zone
We are proposing to introduce a Clean Air Zone across the whole of Greater Manchester in two phases from 2021 and 2023. Vehicles with the highest nitrogen dioxide emissions would need to pay a daily penalty to enter and/or travel within the whole of Greater Manchester.

The Greater Manchester-wide Clean Air Zone would be introduced in two phases:

  • Phase 1: (from 2021) daily penalty for non-compliant HGVs, buses and coaches, taxis and private hire vehicles
  • Phase 2: (from 2023) expanding to non-compliant vans, minibuses, motor homes and motorised horseboxes

As well as cars, motorbikes and mopeds, these vehicles wouldn’t be liable for a penalty payment as their engines are cleaner:

  • Ultra-low emission vehicles
  • Bus/HGV – Diesel Euro 6 engine (from 2013)
  • Van and minibus – Diesel Euro 6 (from 2016)
  • Taxis and private hire vehicles – Diesel Euro 6 (2015 onwards)
  • Taxis and private hire vehicles – Petrol Euro 4 (2005 onwards).

Exemptions or discounts would also apply, details of which will be developed through engagement and consultation with businesses and residents.

The Clean Air Zone would cover the whole of Greater Manchester, so we don't shift pollution from one area to another. In our current proposal the boundary of the zone is in broad terms the administrative boundary of Greater Manchester. The exact boundary will be developed by looking in detail at the layout of the road network and using feedback from this conversation. It will be included in the statutory public consultation for further feedback.

  • Do you have any comments on the boundary?
    • It looks sensible.
  • Do you think the following penalty payments for those vehicles that do not meet minimum emission requirements are too much, too little, or about right?
    • With regard to taxis and private hire vehicles we feel £7.50 per day is too much. Furthermore the proposed penalty charge notice, in addition to the daily penalty charge of £120 per day, is also too much.
  • Do you have any comments about the Clean Air Zone? This may include the area the zone covers and the timescales for introducing the zone
    • The timescale may prove very difficult for many taxi and PHV drivers.

Proposed Daily Penalties
The Clean Air Zone would operate 24 hours a day, seven days a week. Non-compliant vehicles driving into, within or through Greater Manchester would be subject to a daily penalty, except for journeys made only on the strategic road network (these are motorways and some major trunk roads).

If the daily penalty is not paid, the driver would be subject to an additional Penalty Charge Notice (PCN) charge. We are proposing the following daily penalties and PCN charges:

  • Heavy Goods Vehicles (HGV) – £100 from 2021
  • Buses and coaches – £100 from 2021
  • Taxis and private hire vehicles – £7.50 from 2021
  • Vans, minibuses, motor homes and motorised horseboxes – £7.50 from 2023
  • Proposed Penalty Charge Notice – £120 (in addition to the daily penalty)

Any income from the Clean Air Zone would be used to cover the costs of running it. Any leftover money thereafter would be spent on improvements to public transport and cycling and walking schemes.

Vehicles Not Subject to the Daily Penalty
Vehicles with Euro 6 diesel engines, Euro 4 or newer petrol engines and ultra-low emission vehicles are compliant, so would not pay a daily penalty in the Clean Air Zone.

Cars (excluding those registered as a private hire vehicle), motorbikes and mopeds would not be charged as they are outside the scope of the proposals.

In addition, Government has set out a list of specific vehicle types that should generally be exempt from a daily penalty because of their age or unsuitability for replacement or upgrading. You can find out what these are in the summary of our proposals to improve air quality for Greater Manchester document available on their website.

There are no proposals at this stage for any other vehicle types to be exempt from the daily penalty. However, feedback from this conversation may highlight additional vehicles for consideration for an exemption.

  • Why do you say the penalty payments of £100 per day are about right for buses and coaches?
    • Most are likely to be in the area all day, and these will be considerable polluters if not compliant
  • Why do you say the penalty payments of £100 per day are about right for HGVs
    • Most are likely to be delivering in the area all day and will be making a high revenue, and will also considerable polluters if not compliant
  • Why do you say the penalty payments of £7.50 per day are too much for vans, minibuses, motor homes and motorised horseboxes?
    • This is a very poor survey question because these vehicles should not be categorised together! Vans will generally be in the area for commercial reasons, minibuses for passenger transportation reasons, motor homes for spurious reasons and horseboxes for entertainment reasons.
  • Why do you say the penalty payments of £7.50 per day are too much for taxis and private hire vehicles?
    • As previously exampled a compliant vehicle on say a £3.50 job would charge £3.50,a non-compliant driver would have to add £7.50 to a fare, making the fare £11. This in itself is a nightmare to manage. A time in the area charge would be far better as someone in 24 hours a day working as a taxi or PHV will pay the same as someone who enters for minutes. You also have the scenario of when a driver goes into the zone over the threshold time (let's example just before midnight). Do they pay twice? They could do a drop off that took two minutes (one before midnight , one after) and end up paying twice.
  • Why do you say a Penalty Charge Notice of £120 per day is too much if the daily penalty is not paid?
    • You will have all manner of problems with penalty charges for taxis and PHVs because, as previously stated, the owner (registered keeper) of the vehicle could be the driver, the operator, a hire car company, a relative or even an accident repair/maintenance replacement vehicle, so collecting air quality charges is very complex. The facts mean accelerated fines will happen under many circumstances.
  • Do you think there are any other vehicles that should be eligible for exemption from the daily penalty if the Clean Air Zone was introduced?
    • No

Proposed Fnancial Support
Alongside the Clean Air Zone, we are proposing a number of Government-funded schemes for people and businesses in Greater Manchester who own vehicles that would be subject to the Clean Air Zone daily penalty. This financial support would help them to upgrade to compliant vehicles.

Our proposals are based on the expectation that these funds will be available in 2020, so that eligible vehicle owners could apply for funding to help upgrade their vehicles before the first phase of the Clean Air Zone is introduced.

This might be through upgrading their existing vehicle or using retrofit technology to reduce the emissions the vehicle produces, so it becomes compliant. You can find out more about retrofit technologies from the Clean Vehicle Retrofit Accreditation Scheme (CVRAS) on the Energy Saving Trust website.

Further details on the funds, their eligibility criteria and the application process are in development, with the aim of making sure that we help those who need it most first. The information we gather from this conversation will help shape those details. Under our current proposals, the funds will support:

  • Taxis and private hire vehicles licensed in Greater Manchester
  • HGVs and vans, minibuses and coaches (and other commercial vehicles such as motor homes and motorised horseboxes may be eligible) which are registered in Greater Manchester
  • Buses/coaches operating as registered services within Greater Manchester

At this stage we do not know how much funding would be available for each vehicle. We want to find out how much support vehicle owners would need and how we can offer support to upgrade vehicles and reduce air pollution as quickly as possible.

Greater Manchester Clean Air Loan Scheme
The proposals also include a Greater Manchester Clean Air Loan Scheme. If this scheme goes ahead, it could provide loans at preferential rates for those who are taking advantage of the clean vehicle funds.

The details of the loan scheme have not been developed and we will be using feedback from the conversation to help shape our proposals.

  • To what extent do you think that cleaning up Greater Manchester’s bus fleet, heavy goods vehicles (HGV), vans, minibuses and coaches and other commercial vehicles is a priority for improving air quality in Greater Manchester?
    • For Greater Manchester’s bus fleet, heavy goods vehicles (HGV), vans, minibuses and coaches and other commercial vehicles the priority for improving air quality in Greater Manchester is important, and very important for taxi and private hire vehicles.
  • Why did you say that the bus fleet is important as a priority for improving air quality in Greater Manchester?
    • Big vehicles are big polluters but generally owned by profit-making entities so not as important as taxis and PHVs, which are mainly owned by individuals.
  • Why did you say that HGVs, vans, minibuses, coaches and other commercials are important as a priority for improving air quality in Greater Manchester?
    • This is another poor question because it’s a mixture of very different vehicles that perform differing functions and have very differing ownership and revenue models, therefore we've gone for important in the main so not as important as taxis and PHVs, which are mainly owned by individuals.
  • Why did you say that taxis and private hire vehicles are very important as a priority for improving air quality in Greater Manchester?
    • Taxis and PHVs are mainly owned by individuals who will have the most difficulty transitioning
  • Do you have any comments on the funds?
    • Yes, as much help as possible should be given to individual taxi and PHV drivers who own their vehicles otherwise they will get into extreme difficulties transitioning into cleaner vehicles.
    • We note you estimate that almost 1,400 – around 26% – of taxis and just over 4,000 – around 36% – of private hire vehicles in Greater Manchester would have to pay a daily penalty if a Clean Air Zone was introduced in 2021.
    • Furthermore because of this you have asked Government for £28 million to support the upgrade of taxis and private hire vehicles which are licensed in Greater Manchester. This equates to just over £5,100 per vehicle, so how will this be allocated? It is reasonable to presume that most of the vehicles will belong to self-employed drivers not fleets or operators.
    • Knowing that the possibility of retrofitting vehicles is limited and can be expensive and the fact that such vehicles remain old, scrappage schemes and incentives would seem sensible. You go on to say that at this stage you do not know how much funding would be available for each vehicle. In light of what we have previously outlined we would say as much of this fund as possible.
    • You also want to find out how much support vehicle owners would need and how should you offer support to upgrade vehicles and reduce air pollution as quickly as possible. Whilst this is complex, this, in our view, will be best achieved by supporting the move to hybrid vehicles, as there are great limitations in the supply of, and infrastructure for, electric vehicles and the cost of both is significant.
    • There are also considerable doubts about lack of supply of electricity, its cost, the carbon footprint of moving completely to electric vehicles, alongside battery life, decommissioning, battery mileage range, replacing, and the associated costs. All this as well as the serious problem that many drivers cannot charge their vehicles at home, and PHV drivers are not able to rank up and charge their cars whilst working like taxis.
    • If they had to stop to charge vehicles whilst working they would not be able to do any work. We have outlined via independent research and journalism the potential difficulties of moving to a wholly electric fleet in Private Hire News edition 86, where industry experts agree there will be major problems.

Helping Greater Manchester Switch to Greener Transport
Our proposals aim to help people, businesses, and organisations, including schools, across Greater Manchester play their part to reduce air pollution.

This could include helping people to use their car less, especially for shorter journeys, helping businesses to change their fleet so it is cleaner, or to change company cars to electric. You can find out more in the summary of our proposals to improve air quality for Greater Manchester document available on their website.

At this stage we want to hear your views about these initiatives and how they could work for you.

  • Would giving advice to your business or organisation and its employees help them to use greener travel for their commute and work activities?
    • Yes
  • How likely is your business to take part in this scheme?
    • Very likely
  • To what extent do you think that giving advice and support for residents, schools and businesses to use less polluting transport is a priority for improving air quality in Greater Manchester?
    • Very important

Helping Greater Manchester go Electric
We want to expand Greater Manchester’s electric vehicle charging network, and almost treble the number of electric vehicle charging points in Greater Manchester. Our proposals include £25 million to install another 600 rapid charging points (300 double-headed chargers) across the ten council areas of Greater Manchester.

There will also be activity to promote electric vehicles across Greater Manchester. You can find out more in the summary of our proposals to improve air quality for Greater Manchester document available on their website.

  • Does your business or organisation currently use electric vehicles?
    • No
  • How likely are you to consider buying or leasing an electric vehicle(s), once the charging points have been installed?
    • Very Unlikely
  • Where do you think the charging points should be installed?
    • Everywhere possible
  • To what extent do you think the installation of more charging points across Greater Manchester is a priority to help improve air quality in the region?
    • Somewhat important
  • Comments about providing electric vehicle charging points
    • Moving solely to current generation of electric vehicles is a massive risk and may well not be the best option in just a few years' time. Placing the infrastructure alone is massively problematic and expensive.
  • Do you have any other comments?
    • The LPHCA is responding on behalf of taxi and PHV operators directly and indirectly their drivers.
    • There are serious concerns that a longer timescale is needed, not only for the above but also to deliver the best long-term solution. Some authorities are introducing this very quickly, Greater Manchester more rationally, which in our considered view, you should be applauded for doing.
    • Even Greater Manchester however does not know what the funding is yet, how it will be disseminated and whether these proposals are really the best way forward.
    • The LPHCA's view is that a well-considered Air Quality Plan, introduced over a realistic timeline, will bring the best option for all stakeholders. This, in turn, will help to deliver the required air quality objectives, which is far better than rushing via the fastest route, taking more risky measures and not meeting the objectives.

The survey closed on 30th June 2019 and all the feedback received will be read and considered to help shape the detailed proposals. A statutory public consultation will be held in the future, and give you an opportunity to have a say on the detailed proposals.